ERIC Files Comment Letter on Draft Forms and Instructions for ACA Reporting

ERIC News Release

Washington, DC – The ERISA Industry Committee (ERIC) recently filed comments with the Treasury Department and Internal Revenue Service on the draft forms and instructions for the Affordable Care Act (ACA) reporting requirements applicable to health plan coverage offered under employer-sponsored plans.

In its letter, ERIC urges the government to provide additional time to comply with the reporting requirements, to simplify the requirements, and to provide a number of clarifications regarding the forms and instructions.  Among others, ERIC asked the government to specify the circumstances under which an employer may apply some of the alternative reporting methods as well as for additional guidance on when employers may use substitute forms.  

ERIC also continues to recommend that the Treasury Department provide a very simplified approach for reporting for 2015, or delay the reporting deadline for a year to allow companies time to analyze the government’s forms, instructions, and regulations, and then develop their systems to be able to capture and report the relevant data.  

“Given the delay in issuing the forms and instructions and the other obstacles facing most, if not all large employers, the approximately three months provided (i.e., prior to commencement of the first year, 2015, for which reporting is required) will be insufficient to create the significant reporting infrastructure necessitated by these rules, especially one that is capable of capturing data starting in 2015 and reporting the information in early 2016,” wrote Debra Davis, Vice President for Benefits.  

ERIC’s letter can be accessed by clicking on the link below:

ERIC Comment Letter


All media inquiries to The ERISA Industry Committee should be directed to:

Kelly Broadway, 202.627.1918,

About the ERISA Industry Committee
ERIC is the only national association that advocates exclusively for large employer plan sponsors on health, retirement, compensation, and paid leave public policies at the federal, state, and local levels. With member companies that are leaders in every sector of the economy, ERIC promotes uniformity and flexibility for nationwide benefit plans.